This is a Category B project as per IFC’s Policy on Environmental and Social Sustainability (2012). Key E&S risks and issues associated with this project include: effective implementation and enforcement of the company’s environment and social management systems (ESMS) both at corporate and project levels throughout the project lifecycle; assurance of fair, safe and healthy working conditions including occupational health and safety (OHS) aspects during the ongoing COVID-19 pandemic; the company’s land purchase process vis-à-vis the requirements of PS5; resource efficiency; life and fire safety infrastructure and onsite emergency preparedness and response; community health, safety and security; and stakeholder engagement.

Indospace has formulated and implemented a corporate environmental and social management systems (ESMS) in October 2018 in compliance with the requirements under the previous IFC investment. As part of its corporate ESMS, Indospace has documented policies that are developed based on national regulations; IFC Performance Standards; WBG EHS Guidelines and IFC EDGE green building certification standards.

Indospace has developed 3 core policies covering aspects such as: E&S; health and safety; and stakeholder engagement. The corporate ESMS also includes several documented procedures for managing E&S aspects during projects design, construction and operation. All the projects are subjected to above ESMS process and accordingly, for every new project, an E&S due diligence (ESDD) report is prepared by an independent third-party consultant and project specific environmental and social action plans (ESAP) are developed. The corporate ESMS, including the corporate health, safety and environment (HSE) manual, provides guidance on developing environment, health and safety (EHS) management plans for construction and facility management. Indospace has instituted E&S management structure at corporate, regional and project level for coordinating and implementing the ESMS process and elements, which is commensurate with the operational E&S risks and impacts.

A generic emergency response plan (ERP) covering potential major emergencies has been formulated as part of corporate HSE manual and implemented at project sites. Site HSE team reports weekly and monthly on E&S performance in a prescribed format to the corporate team. Corporate team undertakes quarterly audits of each site under construction and coordinates third party external auditing as part of ESMS requirements once in a year. Based on the monthly site reports and audit reports, E&S performance of each of the projects is reviewed in the quarterly senior management review meetings. During operational phase, facility management team works closely with E&S team to ensure all EHS aspects are implemented, monitored and reported back to corporate team. E&S performance reviews and internal audits are carried out at half-yearly frequency.

The company’s E&S management systems were noted to be commensurate with the scale and E&S risks and impacts of its operations; and the implementation at the project level to be robust based on virtual appraisal.

As of September 2020, the company employed 229 on roll staff, of whom about are 18% female employees. In addition, the company has 194 off-roll staff from third party service providers engaged in security, housekeeping services in company office. For future developments, typically the company will have 3 of its on-roll staff and 4 employees from the project management consultants at every site, in addition to construction workers (about 600 at the peak of construction). At Luhari III project site, 194 contractor staff have been mobilized at site and 6 project management consultant staff are deployed for construction supervision as of September 2020.

Indospace has documented HR policies and procedures that are consistent with the national labor regulations and IFC PS 2 requirements. The policies and procedures are made available to all on-roll staff of the company. The company does not prohibit the freedom to associate and workers right to form and join workers organization. The company policies encourage non-discrimination and equal opportunity for its on-roll staff, contract staff and contractor workers. Indospace HR policies and HSE construction manual prohibits engagement of child, forced or bonded labor practices.

Indospace has documented grievance mechanism for its internal stakeholders in line with its HR policy commitments made in its care & dignity policy, whistle blower policy and prevention of sexual harassment (POSH) policy. Grievance mechanism provides for redress available through three levels of escalation in a time bound manner with an established grievance redress procedure and allows for anonymous complaints to be raised. The grievance mechanism is also available to the contractors’ workers and they are included in related training and awareness campaigns conducted by HR department.

Indospace requires its contractors to comply with national labor laws through specific contract clauses. The labor engagement practices, and statutory documentation maintained by the contractors are subjected to monthly labor audits undertaken by independent third-party agency.

At project sites, construction contractors engaged by the company set-up temporary workers housing camps at an off-site location closer to project construction site. Indospace has formulated specifications for labor camp which are made part of contract agreements and enforced during construction phase. As a condition of IFC investment and as per ESAP#1, company shall review and update its labor camp specifications to meet benchmark standards recommended as per Part II: Standards for and management of workers accommodation, Workers’ accommodation: processes and standards, A guidance note by IFC and the EBRD, August 2009. The labor camp specifications shall be updated with regards to sizing of room and dormitory facilities; bed arrangements and storage facilities; canteen, cooking and laundry facilities; standards for nutrition and food safety; medical and first aid facilities; and leisure, social and telecommunication facilities. The updated labor camp specifications shall be included in the corporate ESMS and the revised contract clauses.

Occupational Health and Safety: The company has formulated a health and safety policy and has developed its Corporate HSE manual in 2016 which addresses OHS aspects at the construction site. EHS Corporate team collects the HSE statistics from regional EHS officers on a monthly basis from each site. In the last 3 years there has been no fatal accidents at any of the sites in India. The company has set a target to achieve zero accidents for FY20-21 across its project sites.

OHS Management during COVID 19 pandemic: The company has formulated and implemented COVID-19 response strategies and management plans including a standard operating procedure (SOP) to resume business operations and employee handbook for COVID-19. No significant health impact due to COVID-19 on the company’s and contractor workforce has been reported. The company has not retrenched any staff and there has been no reduction in salary/wages or deferment of wage payments during the ongoing pandemic. Migrant workers staying in the labor camps were provided with free food and shelter through the lockdown period and the company facilitated transport arrangements for workers to return to their homes.

Indospace is committed to develop all its projects in a sustainable manner and had signed up to IFC’s EDGE certification (for energy efficiency) for all projects proposed under the fund III platform. Accordingly, several resource efficiency and sustainability parameters have been integrated in the project design briefing. Additionally, the company has initiated projects to install solar rooftop on each of its warehouse buildings; the electricity generated will be supplied to tenants of the warehouse complex through a power purchase agreement (PPA).

Indospace has engaged independent third-party consultant for GHG verification and certification covering 15 operational parks currently. Based on the company’s current GHG footprint, the GHG emissions from the proposed projects are estimated at 0.018 tons of CO2e /sq.ft/ yr; with about 9.7 million sqft of built-up area proposed to be developed under the project, the total GHG emissions from the project are estimated at 174,000 tons of CO2e/year.

Water is sourced from either onsite groundwater abstraction wells, after receiving appropriate permits; or purchased from private water tankers. All project sites will have rainwater and stormwater harvesting schemes designed and implemented as part of project development mandatorily. All the warehousing projects developed by Indospace have provision for adequate wastewater treatment; the treated wastewater is recycled and reused within the park for cooling tower make-up water purposes, gardening and landscape development and toilet flushing; thereby achieving zero discharge in compliance of local permit conditions.

In industrial warehousing parks there are no major air and noise pollution sources other than diesel generator (DG) sets that are installed for backup power at park level (for sustaining common area services) and individual warehousing buildings (installed and operated by the tenants). Acoustic enclosure and stack heights are designed as per local permitting conditions.

During construction phase much of the construction and demolition wastes generated at site are reused within the site itself and other salvageable wastes are disposed through authorized recyclers. During operational phase, each project is equipped with organic waste composter for onsite biodegradable waste management and the manure generated is used for landscaping and gardening inside the park. Non-biodegradable including hazardous wastes, if any, generated at individual buildings are to be managed by respective tenants as per the permitting conditions.

Industrial warehousing parks built by Indospace are used for leasing space to customers who store goods that are nonflammable and non-hazardous in nature.  In some cases, light manufacturing or assembling is done by select customers inside the buildings. Tenants who intend to store and handle hazardous materials must comply with prevailing national regulations and permit conditions which is monitored by facility management team.

The warehouse structure design and infrastructure development are based on relevant National Building Code (NBC) and Bureau of Indian Standards (BIS) provisions and their compliance is evaluated & certified by independent third-party competent professional post construction.

All projects are designed with life and fire safety infrastructure in compliance with regional and local statutory codes, NBC and local permitting requirements. Inside the buildings, the tenants are responsible for setting up the required life and fire safety infrastructure and obtaining fire permit documents as applicable to their operations.

Corporate ESMS provides guidance for developing and implementing site specific traffic management plan both during construction and operational phases of the projects. The industrial warehousing parks are located inside or closer to operational industrial estates or near important traffic network locations for easy access with no community settlements abutting the park boundary.

Unarmed security team at each project site is mobilized through outsourced agencies with valid licenses issued by local regional competent authorities. Security team is trained on emergency response plan, community engagement and grievance redress, gender aspects, labor regulations, first aid and mock drills.

Indospace has formulated stakeholder engagement policy, and Indospace ESMS provides for consultations with the project team, land-owners and neighboring communities during the ESDD process.

The company discloses project related information (https://www.indospace.in/overview-parks.html) and the project specific environmental compliance report (https://www.indospace.in/about-us/er.html) on its website. Indospace is preparing to publish its first ever Environmental, Social and Governance (ESG) Annual report by end of October 2020.

Grievance redress mechanism (GRM) to address both internal and external stakeholder grievances is in place to address grievances from neighborhood community due to land purchase and resettlement issues, project activities, CSR interventions, employee-community conflicts, or any other project related issues. A grievance register is maintained at every site by the security team which is trained on local community interaction and community grievance redressal. At each site, a stakeholder engagement team is made responsible for continuous interaction with local community on an ongoing basis.

The company will locally disclose the social and environmental information for the project at the following locations:

Any queries and/or comments about the project may be directed to: